The Logic and Practice of Transfer Pricing, Second Edition [Book]

Author (s) : Sam Sim Ziad Rahman
This second edition of the UK Chartered Institute of Taxation Advanced Diploma in Taxation recommended book is written by two practitioners experienced in working in and leading global in-house teams for US and European MNEs.

Publication Date: February 2022

Publisher: LexisNexis

Product Format Details Qty
Book
SG$ 218.00
In Stock ISBN: 9789815019735
This second edition of the UK Chartered Institute of Taxation Advanced Diploma in Taxation recommended book is written by two practitioners experienced in working in and leading global in-house teams for US and European MNEs. Together the authors draw from decades of experience between them in the field of Transfer Pricing and tax. They explain transfer pricing in a logical, clear and easy-to-understand way with use of diagrams and practical illustrations. The book covers the principles of transfer pricing, the aspects to be considered in performing functional analysis (with sample functional templates) and benchmarking, transfer pricing in the context of the global value chain, documentation, transfer pricing risk management and managing controversies.

PART I—The Core

Chapter 1: The Intuition Behind Tax Transfer Pricing

Chapter 2: The OECD Approach

Chapter 3: The Arm’s Length Principle

Chapter 4: Applying the Arm’s Length Principle: Comparability Analysis

Chapter 5: Pulling It Together

Chapter 6: Documentation

Part II—Key Areas of Transfer Pricing and Base Erosion and Profit Shifting (‘BEPS’)

Chapter 7: Intra-Group Service Charges

Chapter 8: The G20-OECD Initiative Against Base Erosion and Profit Shifting

Chapter 9: Special Considerations for Intangibles

Chapter 10: Business Restructuring

Chapter 11: Permanent Establishment and the Authorised OECD Approach

Part III—Transfer Pricing in Motion: Practical Perspectives from Implementing Transfer Pricing

Chapter 12: Audit and Dispute Resolution

Chapter 13: Transfer Pricing in Practical Context

Chapter 14: Developing the In-house Transfer Pricing Capability

Chapter 15: Practicing Transfer Pricing in Non-OECD Developing Countries

Part IV— Cutting Edge Developments

Chapter 16: Financial Transactions

Chapter 17: Making Sense of Base Erosion and Profit Shifting (BEPS) 2.0

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